Before the Court are (1) Plaintiff's motion for leave to amend the Complaint to conform to proof; (2) Defendants' motion for leave to amend their Answer to conform to proof and to add a statute of limitations defense; and (3) Plaintiff's continued motion for partial judgment notwithstanding the verdict. Having reviewed and considered the parties' papers, and for the reasons discussed below, the Court DENIES all three motions.

In her motion to amend the Complaint to conform to proof, Plaintiff largely relies on multiple authorities that discuss a party's ability to amend its pleading to conform to proof before or during trial, or after trial but before judgment. Here, however, Plaintiff is moving to amend the pleading after judgment has been entered, and so the Court's discussion focuses on authorities concerning the current procedural posture.

The Code of Civil Procedure does not indicate when an amendment to conform to proof is allowed. (Code Civ. Proc. §§ 469, 470.) Case law on the